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NEW YORK LIFE INS. CO. v. BOWERS

No. 129.

39 F.2d 556 (1930)

NEW YORK LIFE INS. CO. v. BOWERS, Collector of Internal Revenue.

Circuit Court of Appeals, Second Circuit.

March 3, 1930.

Attorney(s) appearing for the Case

James H. McIntosh, of New York City, for plaintiff.

Samuel C. Coleman, of New York City, for defendant.

Before L. HAND, AUGUSTUS N. HAND, and CHASE, Circuit Judges.

L. HAND, Circuit Judge.

The plaintiff is a large mutual life insurance company with its principal place of business in New York. In common with other such institutions it had before 1906 issued policies in consideration of equal yearly premiums, the accumulated dividends from which it retained for a fixed period, and divided among those who survived and had kept their policies alive when the period expired. These are semi-tontine policies. Besides these it did the...

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